USACM Submits Comments to the FCC on Accessibility Waiver Request for E-Readers

USACM Submits Comments to the FCC on Accessibility Waiver Request for E-Readers

By Renee Dopplick, ACM Director of Public Policy

September 3, 2013

USACM today submitted comments to the FCC on a request by the Coalition of E-Reader Manufacturers to exempt e-readers from the accessibility requirements under the advanced communication provisions of the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA).

Congress passed the CVAA to help ensure that people with disabilities are able to utilize the Internet-based communications technologies of the 21st century, including mobile devices and technologies. The law allows the FCC to waive the accessibility requirements for features, functions, or classes of equipment “designed primarily for purposes other than using advanced communications services.” Advanced communications services under the CVAA include interconnected VoIP services, non-interconnected VoIP services, electronic messaging services, and interoperable video conferencing services.

Here, the Coalition seeks a waiver for e-readers, as a class of devices. The Coalition states that “e-readers are devices designed, built, and marketed for a single primary purpose: to read written materials such as books, magazines, newspapers, and other text documents on a mobile electronic device.”

In its public comment, USACM:

agrees with the Coalition that e-readers designed primarily for reading meet the waiver eligibility criteria under the CVAA;

cautions against distinguishing e-readers from other classes of devices based on screen type, storage capacity, and processing speed;

observes that current product lines of e-readers previously demonstrated the technical capability to provide audio;

recognizes the value of accessibility to a broad range of users beyond users with disabilities; and

recommends a limited-time rather than permanent waiver, should the FCC grant the waiver.

To review the Coalition’s waiver request for e-readers, related documents, and other public comments submitted to the FCC, use the FCC’s electronic comment filing system to search for filings. The Proceeding Number is “10-213.”